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IECEx Industry Seminar Integrating IECEx and ATEX for Europe
Ron Sinclair Managing Director – Baseefa
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ATEX Directive 94/9/EC Council Directive 94/9/EC of 23 March 1994 on the approximation of the laws of the Member States concerning Equipment and Protective Systems intended for use in Potentially Explosive Atmospheres ATEX = “Atmosphere Explosible” = Potentially Explosive Atmosphere
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ATEX Directive 94/9/EC Applicable throughout European Economic Area (EEA) = EU (25)+ EFTA (3) (+Switzerland) = 29 Voluntary application since 1996 Compulsory application since 2003 It is a “Trading Directive” Concerns safety only to set minimum levels to prevent concerns on safety being a barrier to trade
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ATEX Directive 94/9/EC Broad Scope
Equipment (Motors, Luminaires, Diesel Engines, Pumps, Fans, Conveyor Belts Instrumentation, etc.) Protective Systems (Flame Arresters, Suppression Systems, Venting, etc.) Safety Related Devices (IS Safety Barriers, Motor Protection Relays, etc.)
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ATEX Directive 94/9/EC Compliance against “The Essential Health and Safety Requirements” (EHSRs) from Annex II Standards have a subsidiary role supporting claims of compliance Harmonised standards are deemed to demonstrate compliance Use of other standards has to be justified
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ATEX Directive 94/9/EC Compliance against EHSRs to be reviewed against “State of the Art” of technological development Harmonised standards are presumed to show “State of the Art” Other standards may be even more valid but justification for use must be provided
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ATEX – Is it Certification ?
ATEX is a mandatory legal device Only partly certification Process depends on Category The key document, “The Declaration of Conformity” (DoC) is always issued by the manufacturer without any monitoring by a third party The DoC may, or may not, be reliant on evidence from a third party
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IECEx vs ATEX IECEx is a true Type 5 Certification Scheme for all equipment, giving the identical level of confidence for everything ATEX only approaches Type 5 level for Category 1 Equipment and Protective Systems, giving progressively lower confidence for the lower Categories
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IECEx vs ATEX IECEx ATEX Category 1 (or Cat. 2 electrical)
ExTR + QAR >> Certificate of Conformity (issued by IECEx Certification Body and searchable on IECEx web site) ATEX Category 1 (or Cat. 2 electrical) EC-Type Examination Certificate + Quality Assurance Notification (or ??) >> Declaration of Conformity (issued by manufacturer on own responsibility)
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IECEx vs ATEX IECEx ATEX Cat. 2 non-elec. + Cat 3
ExTR + QAR >> Certificate of Conformity (issued by IECEx Certification Body and searchable on IECEx web site) ATEX Cat. 2 non-elec. + Cat 3 Manufacturer constructed Technical File >> Declaration of Conformity (issued by manufacturer on own responsibility)
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ATEX Advantages Flexibility BUT
need not stick to exact wording of standards if alternative justification against EHSRs is contained in Technical File BUT Not transparent as the only publicly available document is the Declaration of Conformity Technical file invisible to purchaser
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IECEx Advantages Transparency >> Confidence BUT
Conformity is exactly against requirements in declared IEC Standards and Certificates are available on web site BUT Cannot use useful developments in draft standards until finally published and included in ExCB scope
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ATEX Advantages Notified Bodies are readily appointed by Member States
Plenty of choice for manufacturers BUT Some bodies have limited expertise and basis for notification is not clear Some bodies treat essentials (such as provision of a report) as a chargeable extra
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IECEx Advantages Appointment of ExCBs and ExTLs is by a system of peer assessment Transparent and leads to mutual confidence Reporting is obligatory and subject to random peer review Leads to customer confidence in the scheme and therefore value of certificates BUT Prevents those that may be so inclined from cutting corners
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The Route for Europe Target End Point Problem
IECEx Certificates of Conformity fully accepted without further paperwork Problem IECEx is about Safety ATEX is about Trade European Commission would need to change the whole structure of its approach to trading directives !
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The Route for Europe Interim Solution 1
IECEx Documentation accepted with an ATEX “Cover Sheet” All the technical work is done once within the IECEx framework Possible currently for all series standards except Ex ‘i’ Possible for all series standards as soon as next edition of is published
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Interim Solution 1 Works best when single body does all the work
ATEX QAN based on IECEx QAR EC-Type Examination Certificate based on ExTR N.B. Purpose of IECEx CoC and EC-Type Examination Certificate are different
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Interim Solution 2 Involving two certification bodies
One outside Europe One inside Europe Need for additional report to show how the ExTR is accepted for ATEX Need for QAN based on QAR Issues of accreditation, notification and public liability insurance for the European Body
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Interim Solution 2 The ATEX Notified Body has to take full legal responsibility and show the necessary paperwork The Notified Body is responsible to the European Commission via its national government
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The Paper Trail All certification activities require a paper trail
The IECEx Scheme paper trail is prescribed to a major extent within the scheme The ATEX Directive does not prescribe particular forms of paperwork
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The Paper Trail The IECEx paper trail is satisfactory for ATEX
Most forms of paper trail devised for ATEX would not be acceptable for IECEx It is not unknown for a European Notified Body to refuse to release the report to its customer !
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The Baseefa Philosophy Production Control
All work being done for ATEX QANs is being reported in a format acceptable for an IECEx QAR The customer gets exactly two for the price of one We do no extra work, so there is no extra charge
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The Baseefa Philosophy Design Test and Assessment
If our customers are able to use standards acceptable to IECEx there is no extra charge for the technical work There are additional sheets of paper to cover ATEX and IECEx, but the cost is minimal for most projects
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IECEx plus ATEX The Benefits
For very little extra cost Future proofed acceptability throughout the world as the IECEx Scheme grows Legal acceptability in Europe
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